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FEM 2024 - Chemical Management Level 1 (Part 1)

  • Updated

Table of Contents

  1. Chemcmspolicynonprod, Chemcmspolicyprod
  2. Chemcmspolicynonprod, Chemcmspolicyprod Verification And Scoring
  3. Chemcmstraining
  4. Chemcmstraining Verification And Scoring
  5. Chempurchasingpolicy
  6. Chempurchasingpolicy Verification And Scoring
  7. Chemtrack
  8. Chemtrack Verification And Scoring
  9. Chemtrackdatahtml
  10. Chemtrackdatahtml Verification And Scoring
  11. Chemsds
  12. Chemsds Verification And Scoring
  13. Chemtraining
  14. Chemtraining Verification And Scoring
  15. Chememergplan
  16. Chememergplan Verification And Scoring
  17. Chemsafetyequip
  18. Chemsafetyequip Verification And Scoring
  19. Chemhazardsign
  20. Chemhazardsign Verification And Scoring
  21. Chempurchasereqmrsl
  22. Chempurchasereqmrsl Verification And Scoring

Chemcmspolicynonprod, chemcmspolicyprod

  1. Does your facility have a written Chemical Management System (CMS) policy?  (Ref ID: chemcmspolicynonprod / chemcmspolicyprod)

For facilities that do not use Chemicals in Production:(Ref ID: chemcmspolicynonprod)

Answer Yes if: Your facility has a documented Chemical Management System (CMS) policy that covers all of the following elements:

  • Comply with all applicable laws and regulations.
  • The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact. 
  • Capacity building and training of staff on CMS. 

For facilities that use Chemicals in Production:(Ref ID:chemcmspolicyprod)

Answer Yes if: Your facility has a documented Chemical Management System (CMS) policy that covers all of the following elements:

  • Comply with all applicable laws and regulations.
  • The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
  • Capacity building and training of staff on CMS.
  • Incorporating traceability and transparency into your facility’s operations.
  • Incorporating sustainable chemical management practices in production processes
  • Commitment to continuously improve CMS effectiveness.

Answer Partial Yes if: Your facility has a documented Chemical Management System (CMS) policy that covers the three (3) elements listed below, but not all of the three (3) additional elements listed above:

  • Comply with all applicable laws and regulations.
  • The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
  • Capacity building and training of staff on CMS.

If you select Yes or Partial Yes, you will be asked the following sub question(s): 

  • Which of the following has been included in the policy (Select all that apply):
    • Comply with all applicable laws and regulations.
    • Ensuring the safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
    • Capacity building and training of staff on CMS.

Suggested Uploads: 

  • A copy of the facility’s Chemical Management System policy. 

What is the intent of the question?

The intent of this question is for facilities to demonstrate that a formal policy is in place for managing chemicals safely and effectively. 

Technical Guidance

A chemical management system policy is the foundation for a facility’s chemical management system. A policy is important to make sure all stakeholders (internal and external) are aware of the goals of the facility with respect to chemicals management. A CMS policy should include a clear statement that outlines a facility’s commitments to chemicals management. and provide details on the practices and procedures followed by the facility.  

The specific content of a chemical management system policy may vary based on the nature of chemicals used at a facility. For example, a facility that only uses chemicals in facility operations (e.g., machine maintenance and lubrication) versus a facility with chemical intensive manufacturing processes. However, there are some key basics elements that should be included such as commitments to:

  • Comply with all applicable laws and regulations. 
  • Reduce risks to workers and the environment.
  • Training and capacity building for staff
  • Communicate the policy and associated CMS procedures to all relevant parties (e.g., staff, external stakeholders, etc.) 

For facilities that use chemicals in production additional policy elements should be included such as commitments to:

  • Continuous improvement of the CMS effectiveness.
  • Incorporate sustainable chemical management practices in its production processes.
  • Incorporate traceability and transparency into its operations. 

A CMS policy should also be regularly reviewed and updated as needed. To ensure it provides a framework for continuous improvement, allowing facilities to identify areas where they can improve their chemical management practices and reduce risks.

Resources:

The ZDHC CMS and Technical Industry Guide framework sets out the principles and practices that should be included in a CMS policy and CMS, which are designed to help companies establish a robust and effective CMS that meets the ZDHC framework requirements and reduces the environmental and health impacts associated with chemical use in the supply chain.

  1. The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance   

Chemcmspolicynonprod,chemcmspolicyprod Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • For facilities that use do not use Chemicals in Production, Documented Chemical Management System policy that clearly includes the following elements:
    • Comply with all applicable laws and regulations.
    • The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact. 
    • Capacity building and training of staff on CMS. 
  1. For facilities that use Chemicals in Production, Documented Chemical Management System policy that clearly includes the following elements:
  • Comply with all applicable laws and regulations.
  • The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact. 
  • Capacity building and training of staff on CMS
  • Incorporating traceability and transparency into your facility’s operations.
  • Incorporating sustainable chemical management practices in production processes
  • Commitment to continuously improve CMS effectiveness.
  • Other supporting documentation that shows the facility’s practices and procedures align with the CMS policy. This may include:
    • Communication and/or training records on the facility’s CMS policy
    • CMS procedures
    • Records of management review of CMS policy.

Interview Questions to Ask:

  • Staff responsible for chemicals management at the facility, including top management, and employees are aware of the facility’s CMS policy and can describe the facility’s efforts to meet its stated objectives.

Inspection - Things to Physically Look For: 

  • Observations onsite are consistent with the facility’s CMS policy (i.e., the policy is relevant to the facility operations and chemical use onsite).
  • Posting of the CMS policy at the site or other forms of communication to staff.

Partial Points (Facilities that use Chemicals in Production only): 

  1. For facilities that use Chemicals in Production, partial points will be awarded to facilities that have a documented Chemical Management System (CMS) policy that covers the three (3) elements listed below, but not all of the three (3) additional elements listed above:
    1. Comply with all applicable laws and regulations.
    2. The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
    3. Capacity building and training of staff on CMS.

Chemcmstraining

5. Have you assigned the responsibility of implementing and maintaining the Chemical Management System (CMS) to a team/staff member?       (Ref ID: chemcmstraining)

Answer Yes if: Your facility has assigned the responsibility of implementing and maintaining the Chemical Management System (CMS) to a team or staff member and there are documented responsibilities for the implementing and maintaining the facility’s CMS (e.g., job description). 

Note: This responsibility may be assigned to a single person/role at the facility or spread across multiple staff members/roles.  

If you select Yes, you will be asked the following sub question(s):

  • Which competence(s) does your CMS team have: (Select all that apply)
    • Ability to read and interpret SDS.
    • Competency in RSL
    • Competency in MRSL
    • Knowledge of GHS of classification and labelling or equivalent as well as local and international regulations on chemical restrictions

Note: Competency means that the individual has received formal qualification, education, training, and/or has professional experience that allows the person to understand and manage the noted aspect in relation to the facility’s CMS. 

Suggested Uploads: 

  • List of staff responsible for implementing and maintaining the CMS and their responsibilities (e.g., documented job description).
  • Documented CMS procedures that include responsibilities of staff related to CMS implementation.
  • If applicable, documentation that demonstrates the competencies of staff assigned to implement the CMS (e.g., certification, training records, curriculum vitae (CV)).

What is the intent of the question?

The intent of this question is for facilities to demonstrate they have dedicated roles and responsibilities established and staff assigned for the implementation and maintenance of the facility’s CMS.

Technical Guidance

Assigning a team/staff member and having defined roles and responsibilities for implementing and maintaining the facility’s CMS creates a clear chain of accountability for chemicals management within the facility. This is the foundation to effective implementation of a facility’s CMS.  

Based on the size and scope of operations, a facility can decide on the number of staff required for CMS implementation. It is good practice to have a Chemical Responsible Person or a Core Team, composed of trained, capable, and experienced personnel to oversee the implementation and monitoring of a CMS.

Implementing and maintaining a CMS at a facility requires an in-depth understanding of chemicals management principles. One of the major barriers to effective implementation of a CMS is the lack of technical competencies in chemicals management. A team with appropriate competencies in chemicals management, helps facilities better understand the risks and impacts of chemicals in use, and helps to identify and implement appropriate measures to mitigate those risks and make improvements. Also, it helps ensure compliance with relevant regulations and other requirements, which are constantly evolving and becoming more complex.

Resources:

The ZDHC CMS and Technical Industry Guide framework sets out the principles and practices that should be included in a CMS which are designed to help companies establish a robust and effective CMS that meets the ZDHC framework requirements and reduces the environmental and health impacts associated with chemical use in the supply chain.

Chemcmstraining Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have assigned the responsibility of implementing and maintaining the CMS to a team or staff member and the team is comprised of individuals that are competent in the following chemicals management aspects: 

  • Ability to read and interpret SDS.
  • RSL
  • MRSL
  • GHS of classification and labelling or equivalent as well as local and international regulations on chemical restrictions

Note: Team members do not need to be competent in all aspects noted above, however there must be at least one (1) team member who is competent in each of the aspects.

Documentation Required:

  • Documentation that shows the facility has assigned the responsibility of implementing and maintaining the CMS to a team or staff member and there are documented responsibilities for the team member(s).  This may include:
    • List of staff responsible for implementing and maintaining the CMS and their responsibilities (e.g., documented job description).
    • Documented CMS procedures that include responsibilities of staff related to CMS implementation.
    • If applicable, documentation that demonstrates the competencies of staff assigned to implement the CMS (e.g., certification, training records, curriculum vitae (CV)).

Interview Questions to Ask:

  • Staff responsible for chemicals management are able to explain the roles and responsibilities of staff or team members related to the CMS.
  • Relevant staff responsible for the implementation and maintenance of CMS are able to demonstrate their competency in SDS, RSL, MRSL, GHS for classifications and labelling or equivalent. 

Inspection - Things to Physically Look For: 

  • Observations indicate that CMS are being managed by staff with appropriate technical competency and the facility’s chemicals management practices are in line with the CMS.

Partial Points:

  • Partial points will be awarded to facilities that have assigned the responsibility of implementing and maintaining the CMS to a team or staff member, but the team member(s) have at least one, but not all of the competencies listed below: 
  • Ability to read and interpret SDS.
  • RSL
  • MRSL
  • GHS of classification and labelling or equivalent as well as local and international regulations on chemical restrictions

Chempurchasingpolicy

6. Does your facility have a chemical purchasing policy? (Ref ID: chempurchasingpolicy)

Answer Yes if: Your facility has established a formal documented chemical purchasing policy.

If you select Yes, you will be asked the following sub question(s):

  • Which of the following criteria are being included into consideration in your chemical purchasing policy: (Select all that apply):
    • Legal requirements 
    • Health and Safety requirements 
    • RSL and/or MRSL requirements 

Note: RSL and MRSL requirements refers to both brand specific requirements and the requirements of other industry programs (e.g., ZDHC, bluesign, etc)

Suggested Uploads: 

  • A copy of the facility’s chemical purchasing policy

What is the intent of the question?

The intent of this question is for facilities to demonstrate that a chemical purchasing policy is in place to ensure that chemicals are screened against established criteria before being purchased.

Technical Guidance

Establishing a formal chemical purchasing policy helps ensure chemicals are appropriately screened before being purchased. A chemical purchasing policy should clearly define the criteria for chemicals that can and cannot be purchased (e.g., specific legal or other requirements, health and safety considerations, etc.)  The goal of the policy should be to reduce risk of hazardous or non-compliant chemicals entering the facility.  

When developing a chemical purchasing policy, facilities should consider the following key elements of an effective chemical purchasing policy:

  • Developing specific criteria (e.g., legal or other requirements) for selecting chemicals to purchase.
  • Detailed procedures and responsibilities for the review and approval of chemicals before they are purchased.
  • Procedures to communicate the policy and purchasing criteria to chemical suppliers (e.g., including terms and conditions in contracts and/or purchase agreements).
  • Requirements for suppliers to provide sufficient chemical information for review, such as providing safety data sheets (SDS), labelling requirements, lot numbers, expiry dates, and other information on the environmental and health impact of their products.
  • Procedures to ensure that staff are trained on the policy and understand the importance of selecting appropriate chemicals for use at the facility.

Resources:

The ZDHC CMS and Technical Industry Guide framework sets out the principles and practices that should be included in a CMS including chemicals purchasing which are designed to help companies establish a robust and effective CMS that meets the ZDHC framework requirements and reduces the environmental and health impacts associated with chemical use in the supply chain.

Chempurchasingpolicy Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • Documentation that shows the facility has an established chemical purchasing policy. This may include:
    • Chemical purchasing policy that outlines how chemicals are screened against established criteria before being purchased.
    • Chemical purchasing records that demonstrate chemicals are being purchased in line with the established chemical purchasing policy.
  • Other supporting documentation that shows the facility’s practices and procedures align with the chemical purchasing policy. This may include:
    • Communication and/or training records on the facility’s purchasing policy.
    • Chemical procurement procedures.

Interview Questions to Ask:

  • Staff responsible for chemical purchasing at the facility are aware of the facility’s policy and can describe their process screening and purchasing chemicals in line with the established policy.

Inspection - Things to Physically Look For: 

  • Observations onsite indicate the chemicals are being purchased in line with the purchasing policy (e.g., all chemicals onsite are covered in the purchasing policy

Partial Points: N/A

Chemtrack

7. Does your facility keep a Chemical Inventory List (CIL) and the suppliers of each chemical product? (Ref ID: chemtrack)

Answer Yes if: Your facility has an up-to-date chemical inventory list (CIL) that includes all chemicals used at the facility. 

Answer Partial Yes if: Your facility has an up-to-date chemical inventory list (CIL) that includes some, but not all chemicals at the facility.

Note:  Up-to-date means that the information in the inventory includes all chemicals currently in use and accurately reflects chemical use at the facility (e.g., chemicals that are not currently onsite, but are commonly used within and by the facility). 

If you select Yes, you will be asked the following sub question(s):

  • Does your facility include the following types of chemicals in the inventory?
    • All chemicals used in manufacturing processes (including chemicals in production, reactants and additives.
    • All chemicals used in tooling/equipment (lubricants and grease).
    • All chemicals used to operate and maintain the facility, and wastewater treatment plant chemicals where applicable. 
    • Spot cleaner(s). 
  • Please upload documentation, if available.

Note: To be able to answer Yes to the main question all responses to the sub question must be either Yes or Not Applicable. If any of the responses to the sub questions above are no, the response for the main question must be Partial Yes

If you select Partial Yes or No, you will be asked the following sub questions:

  • For data not included in your facility’s Chemical Inventory List, is there an action plan for obtaining this data?
    • Upload your action plan for obtaining this data.
    • If you don't have a document to upload, describe your plan.

Suggested Uploads: 

  • A copy of the facility’s Chemical Inventory List
  • If applicable, documentation action plan to obtain missing information in the inventory.

What is the intent of the question?

The intent of this question is to ensure that facilities have identified and created an inventory of all chemicals onsite.

Technical Guidance

Understanding which chemicals are used within a facility is a necessary first step in building a chemical management system. Identifying all chemicals used and their properties allows a facility to understand and manage regulatory and customer requirements, and ensure appropriate controls are in place to protect workers and the environment. A chemical inventory can also help facilities with purchasing decisions, increase transparency and traceability, and promote responsible chemical use.

Facilities should have a robust process for creating and updating their chemical inventory and have dedicated staff, in charge of maintaining the inventory.

While preparing an inventory, there are some important considerations that should be reviewed including:

  • How to ensure that all chemicals are covered including production and non-production chemicals.
    • An inventory should contain all chemicals used and stored in the facility and may cover, but is not limited to, cleaners, adhesives, paints, inks, detergents, dyes, colourants, auxiliaries, coatings and finishing agents, and commodity chemicals, as well as those used for ETP, sanitary, laboratory and utility purposes.
  • What information is needed in the inventory to manage the chemicals effectively and safely and how this information will be obtained (e.g., from chemical suppliers, SDS, other sources, etc). Key information that should be included, but is not limited to, the following:
    • Chemical name and type 
    • Supplier/Vendor name and type 
    • Manufacturer/Formulator name 
    • Safety Data Sheet (SDS), Global Harmonization System (GHS) compliant or equivalent 
    • Function 
    • Hazard classification 
    • Where it is used 
    • Storage conditions and location 
    • Quantities (quantity of chemicals used)
    • CAS number or numbers (when in a mixture) 
    • Lot numbers (if applicable)
    • MRSL conformance 
    • Purchase date 
    • Expiration dates (if applicable)
  • How the inventory will be updated (e.g., addition/removal of new/old chemicals, review frequency and responsible staff).
  • How the inventory may be used to support monitoring of chemical consumption and purchasing to reduce risks of expiry or storage of excessive quantities of chemicals onsite. 

Resources:

The resources below provide example templates and reference information that can support a facility in creating or updating their chemical inventory.

Note: The resources provided below are for reference only and facilities should ensure their chemical inventory complies with any applicable law or regulations. 

Chemtrack Verification And Scoring

How This Will Be Verified:

Full Points: 

Full points will be awarded for facilities that have an up-to-date chemical inventory list (CIL) that includes all chemicals used at the facility. 

Documentation Required:

  • Documentation that shows the facility has a chemical inventory list (CIL) and this the list is up-to-to-date and accurate. This may include:
    • The chemical inventory list (CIL)
    • Purchase records of chemicals

Interview Questions to Ask:

  • Staff responsible for the chemical inventory list are able to explain how the facility ensures that the list is maintained and updated. 

Inspection - Things to Physically Look For: 

  • Observations onsite indicate that the inventory is up-to-date and accurate (e.g., chemicals observed to be in use at the facility are included on the inventory) 

Partial Points: 

  • Partial points will be awarded for facilities that have an up-to-date chemical inventory list (CIL) that includes some, but not all chemicals at the facility.

Chemtrackdatahtml

8. Does your facility's Chemical Inventory List (CIL) include the following data? Select all that apply.  (Ref ID:chemtrackdatahtml)

  • Chemical name and type 
  • Supplier/Vendor name and type 
  • Manufacturer/Formulator name 
  • Safety Data Sheet (SDS), Global Harmonization System (GHS) compliant or equivalent 
  • Function 
  • Hazard classification 
  • Where it is used 
  • Storage conditions and location 
  • Quantities (quantity of chemicals used)
  • CAS number or numbers (when in a mixture) 
  • Lot numbers (if applicable)
  • MRSL conformance 
  • Purchase date 
  • Expiration dates (if applicable)

Notes:

  • Exception for lot numbers: Facilities that do not use chemicals in production, (e.g., spot cleaning or ETP chemicals) that would not lead to RSL, MRSL, ZDHC Wastewater testing failures do not need to include the lot numbers for these chemicals and should check the box for lot number if these are the only types of chemicals used onsite.
  • If a chemical does not conform to specific MRSL requirements, it does not mean the facility does not have a CIL or the required information if the MRSL conformance status is listed. 

Suggested Uploads: 

  • A copy of the facility’s Chemical Inventory List (CIL)
  • Examples of supporting information for the data that is included in the CIL (e.g., SDS, chemical usage records, purchase records, MRSL conformance tests or declarations, etc.)

What is the intent of the question?

The intent of the question is for facilities to demonstrate that their chemical inventory contains the necessary information for each chemical.

Technical Guidance:

An effective chemical inventory should include all information needed to manage the chemicals effectively and safely. For the Higg FEM, the list of information included in this question is considered important to include in an inventory, however there may be additional information that is valuable to support a facility’s management of chemicals. For example, it is also recommended as a good practice to indicate whether chemicals in your inventory are included in a positive list or negative list of any industry standard, if applicable.

The guidance below provides additional details on the type of information to include for the key items in the inventory:

  • Chemical Product and Chemical Formulator name
    • This can be obtained from Section 1 of the SDS where the Chemical Product name and Chemical Formulator name are detailed. This should also be confirmed with the GHS-label on the chemical container.
  • Supplier name
    • In case this is different from Chemical Formulator, such as a trader or distributor.
  • Safety Data Sheet (SDS) Information
    • The date of issue of the SDS should be inputted, only if the SDS for the chemical product is available in the manufacturing facility. In case the SDS is not available or is found to be outdated, a follow-up should be made with the Chemical Formulator to obtain the latest SDS and then the date of issue should be input.
  • Function
    • Indicates the use or application of the chemical.
  • Hazard classification
    • Hazard Statements for the three Hazard Types - Physical, Health and Environmental- should be inputted, as listed in Section 2 of the SDS. 
    • Storage, handling and discharge precautions: Refer to the P-Statements given in Section 2 and Section 7.2 of the SDS
  • Where it is used
    • Input the locations/areas the chemical is used. 
  • Storage conditions and location
    • The location such as the main store, sub-store or a specific storage place can be described here to quickly understand the place of storage. 
  • Quantities (quantity of chemicals used)
    • For example, actual monthly/annual usage amount and unit
  • CAS number or numbers 
    • Input the CAS (Chemical Abstract Service) numbers of the hazardous substances as listed under Section 3 of the SDS.
    • Input the CAS number and % of the substance for mixtures.
  • Lot numbers (if applicable)
    • The batch or lot number(s) of the chemical product purchased in the month can be inputted to establish traceability in case of Root Cause Analysis.
  • MRSL conformance
    • Input the conformance status with any applicable MRSL. 

Resources:

The resources below provide example templates and reference information that can support a facility in creating or updating their chemical inventory.

Note: The resources provided below are for reference only and facilities should ensure their chemical inventory complies with any applicable law or regulations. 

Chemtrackdatahtml Verification And Scoring

How This Will Be Verified:

Full Points: 

Full points will be awarded for facilities that have an up-to-date chemical inventory list (CIL) that includes all of the data points listed in the FEM. 

Documentation Required:

  • Documentation that shows the facilities chemical inventory list (CIL) up-to-to-date and includes accurate information on chemicals in the list. This may include:
    • The chemical inventory list (CIL)
    • Safety Data Sheets (SDS) or Technical Data Sheets (TDS)
    • Chemical usage records
    • Purchase records of chemicals
    • MRSL conformance tests or declarations

Interview Questions to Ask:

  • Staff responsible for the chemical inventory list are able to explain how the facility obtains information in the inventory and ensures that the list is maintained and updated. 

Inspection - Things to Physically Look For: 

  • Observations onsite indicate that the inventory is up-to-date and the associated information in the inventory is accurate (e.g., chemicals observed to be in use at the facility are included on the inventory) 

Partial Points: 

  • Partial points will be awarded for facilities that have an up-to-date chemical inventory list (CIL) that includes some, but not all data points listed in the FEM. 
    • Note: Partial points are calculated automatically in the FEM based on the items that are included in the CIL.

Chemsds

9. Does your facility make Safety Data Sheets (SDS) available to employees for all chemicals used? (Ref ID: chemsds)

Answer Yes if: Your facility has up-to-date SDS information available to employees for all chemicals used and the SDS is at minimum, compliant with country specific regulations and the facility has an established process to ensure that SDS information is kept up-to-date.

Answer Partial Yes if: Your facility has up-to-date SDS information available to employees for some, but not all chemicals used and the available SDS are at minimum, compliant with country specific regulations.

Note:  Up-to-date means that the SDS has been updated at the frequency defined by local law and/or if any of the following have occurred:

  • An ingredient used in the formulation is changed due to which there is an impact on the hazard classification of the formulation.
  • New toxicological/legislative information is applicable to any ingredient used in the formulation that may impact the overall hazard classification of the formulation.
  • Any type of new restriction or authorisation has been imposed on a substance or mixture (e.g., under EU- REACH regulation or other legislation). 

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Are Safety Data Sheets posted readily accessible where hazardous chemicals are stored/used?
  • Are Safety Data Sheets available in languages workers understand (at least sections directly related to operational worker safety and storage requirements, such as first aid, hazard, and flammability information)?
  • Please upload documentation, if available

Notes:  

  • Readily accessible means that SDS information is easily accessed in areas of use. For example, this could be achieved by posting of SDS and/or maintaining SDS information in a folder at a nearby work areas.
  • It is not required to translate all SDS information into the language of workers in its entirety. It is acceptable to create translated simplified data sheets that contain translation of necessary information for workers related to their job function and chemical hazards/safety (e.g., appropriate handling, use, and storage of the chemical, personal protection, proper first aid/emergency response and disposal precautions).

Suggested Uploads:

  • Photo images showing the SDS information available in applicable work areas and accessible to the employees.
  • Copies of SDS 
    • Note: Copies of all SDS do not need to be uploaded but should be available for review during verification.
  • Procedures for ensuring SDS information is up-to-date.

What is the intent of the question?

The intent of this question is for facilities to ensure that up-to-date SDS information is available for all chemicals used in the facility. 

Technical Guidance:

Safety Data Sheets (SDS) are a fundamental source of information on the hazards associated with a chemical. SDS provide crucial information on how to manage chemicals in a responsible manner including how chemicals should be stored, used, handled, and disposed of as well as information on health, safety, and environmental hazards.  

An SDS (either as hard or soft copy) for every chemical used in a facility should be kept at a central location and also in areas where the chemical is stored and/or used so that it is readily accessible by staff. Staff should also be trained on how to read and understand SDS information.

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS/CLP) is an internationally recognized system for the classification and labelling of chemicals. The GHS was developed to replace individual sets of classification and labelling standards used in different countries with a single, standardized set of criteria for the classification and labelling of chemicals and standardized requirements for the information required on SDS.

Country specific levels of GHS adoption may vary, however it is recommended that facilities request GHS compliant SDS form chemical suppliers when available, but at minimum facilities should follow applicable country specific regulations relating to SDS content.

It is also important that SDS information be provided in the language of all workers so that it is easily understood. It is not required to translate all SDS information into the language of workers in its entirety. It is acceptable to create translated simplified data sheets that contain translation of necessary information for workers related to their job function and chemical hazards/safety (e.g., appropriate handling, use, and storage of the chemical, personal protection, proper first aid/emergency response and disposal precautions) or as legally required.

The date of issue of SDS and its version number should be carefully monitored. An SDS needs to be updated by a chemical supplier when:

  • Any ingredient(s) are changed that results in a change to the hazard classification of the chemical.
  • New toxicological/legislative information is applicable to any ingredient(s) that may impact the hazard classification of the chemical.
  • Any type of restriction or authorisation has been imposed on chemical or its ingredient(s) (e.g., under EU- REACH regulation or other legislation).

It is considered a good practice for facilities to monitor the validity of the SDS for each chemical product by checking regularly with the supplier for any potential updates. (Note that the FEM does not define a required frequency for this.) 

In cases where certain SDS information is not available at the point of purchase (e.g., tooling or cleaning chemicals) Facility should strive to obtain as much information about the chemical as possible (e.g., by contacting manufacturers or suppliers provided on the product). Facilities should also ensure these products have appropriate labels which should provide details of ingredients and hazards. In cases where appropriate labels or SDS are not available, the original labels should be compliant to GHS/CLP or country specific regulations.

Resources:

The resources below provide helpful information on SDS management.

Note: The resources provided below are for reference only and facilities should ensure that their SDS management program complies with any applicable laws or regulations. 

Chemsds Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have up-to-date SDS information available to employees for all chemicals used and the SDS is at minimum compliant with country specific regulations and the facility has an established process to ensure that SDS information is kept up-to-date.

Note:  Up-to-date means that the SDS has been updated at the frequency defined by local law and/or if any of the following have occurred:

  • An ingredient used in the formulation is changed due to which there is an impact on the hazard classification of the formulation.
  • New toxicological/legislative information is applicable to any ingredient used in the formulation that may impact the overall hazard classification of the formulation.
  • Any type of new restriction or authorisation has been imposed on a substance or mixture (e.g., under EU- REACH regulation or other legislation). 

Documentation Required:

  • Documentation that demonstrates the facility has up-to-date SDS information available in the workplace and that SDS information is available to workers. This may include:
    • Copies of up-to-date SDS that are at minimum compliant with legal requirements for SDS.
    • Copies SDS information translated into the language of workers.
    • SDS Training records for workers.
    • Procedures that demonstrate the facility has processes in place to ensure SDS information is kept up-to-date.

Interview Questions to Ask:

  • Staff responsible for SDS management at the facility are able to explain the facility’s procedures for Managing SDS information and how the facility ensures up-to-date SDS information for chemicals is obtained and communicated and made accessible to workers.
  • Relevant employees understand the facility’s SDS program and can explain how SDS information is accessed when needed. 

Inspection - Things to Physically Look For: 

  • Observations that indicate up-to-date SDS information is available at the facility and made accessible to workers (e.g., SDS are available for chemicals observed onsite, SDS are stored (in hard or soft copy) in work areas) 

Partial Points:

  • Partial Points will be awarded to facilities that have up-to-date SDS information available to employees for some, but not all chemicals used and the available SDS are at minimum compliant with country specific regulations.

Chemtraining

10. Does your facility train all employees who handle chemicals on chemical hazards, risk, proper handling, and what to do in case of emergency or spill?  (Ref ID:chemtraining)

Answer Yes if: Your facility has provided training to employees and the training meets all of the following criteria:

  • Training has been delivered to all employees who handle chemicals.
  • The Training covers all of the topics listed in the sub question below.
  • The training is documented (with training records and/or material)
  • Training is conducted at least annually or at a frequency that allows training all new employees according to the turnover rate.

Answer Partial Yes if: Your facility has provided training, but one (1) or more of the following criteria is not met:

  • Training has been delivered to all employees who handle chemicals. 
  • The Training covers all of the topics listed in the sub question below.
  • The training is documented (with training records and/or material)
  • Training is conducted at least annually or at a frequency that allows training all new employees according to the turnover rate.

Note: If your facility has not provided training to any employees on chemicals, you should answer No to this question.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Please select all topics included in your training:
    • Chemical hazards and identification
    • MSDS/SDS
    • Signage
    • Compatibility and risk
    • Proper storage and handling
    • PPEs
    • Procedure in case of emergency, accidents, or spill
    • Access restriction to chemical storage areas
    • Potential environmental impact of the chemicals in tanks
    • The physical protection provided to employees in the area(s) where the factory uses, stores, and transports these containers.
    • Individual duties associated with monitoring and maintaining this protection here.
  • How many employees were trained?
  • How frequently do you train your employees?
  • Do you evaluate your employees after the training?
    • How do you evaluate the knowledge of your employees after the training?
  • Please upload documentation.

Suggested Uploads:

  • Documentation that demonstrates the facility has conducted training on chemicals for employees (e.g., Training plan/schedule, training records, training material used for training, post-training evaluation procedures and/or records)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that procedures are in place to train employees who handle chemicals on chemicals hazards and safety, and that trainings have been conducted.

Technical Guidance:

It is important that all levels of employees are aware of chemical hazards, risks, safety precautions and emergency response for chemicals in use at the facility. Facilities should have formal documented training processes to ensure awareness and knowledge is shared with all employees who handle chemicals.

Effective training programs ensure that all levels of employees understand the potential hazards, risks, and controls associated with chemicals in the workplace. Various levels and types of training may be required to ensure training is appropriate for employees in different positions or with responsibilities and directly relates to the types of chemicals they may come into contact with during regular operations or emergency situations.

Having procedures to collect information to evaluate the effectiveness of training programs (e.g., trainee feedback questionnaires or test, observation, or reviews of trainer performance, etc) will help facilities ensure the effectiveness of training and knowledge retention.

Resources:

Chemtraining Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have provided training to employees and the training meets all of the following criteria:

  • Training has been delivered to all employees who handle chemicals.
  • The training covers all of the topics listed in the sub question.
  • The training is documented (with training records and/or material)
  • Training is conducted at least annually or at a frequency that allows training all new employees according to the turnover rate.

Documentation Required:

  • Documentation that shows the facility has provided chemicals related training employees. This may include:
    • Training plan that identifies training schedule(s), topics covered, and type of training for employees.
    • Training attendance records
    • Training material used for environmental training, 
    • Training evaluation procedures and/or records

Interview Questions to Ask:

  • Staff responsible for the facility’s chemical training program can explain how training is provided and if applicable, how the effectiveness of training is evaluated.
  • Employees who have received the training are aware of the content of the training.

Inspection - Things to Physically Look For 

  • Supporting evidence of the facility’s environmental training program (e.g., awareness posters, informational postings related to the facility’s chemical management/safety programs, if available)

Partial Points:

  • Partial point will be awarded for facilities that have provided training, but one (1) or more of the following criteria is not met:
  • Training has been delivered to all employees who handle chemicals. 
  • The Training covers all of the topics listed in the sub question below.
  • The training is documented (with training records and/or material)
  • Training is conducted at least annually or at a frequency that allows training all new employees according to the turnover rate.

Chememergplan

11. Does your facility have a chemical spill and emergency response plan that is practiced periodically?   (Ref ID: chememergplan)

For facilities that use chemicals in production:

Answer Yes if: Your facility has a documented chemical spill and emergency response plan that meets the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework and practice drills are conducted at least twice per year for all relevant staff.

Answer Partial Yes if:  Your facility has a documented chemical spill and emergency response plan, but the plan does not meet the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework  or practice drills are not conducted at least twice per year for all relevant staff.

Note: For this question, relevant staff means any employee or manager that handles chemicals, works in areas where chemicals are used, and/or has defined responsibilities in the facility’s chemical spill and emergency response plan/procedures. 

For facilities that only use chemicals for operations or tooling/equipment:

Answer Yes if: Your facility has a documented chemical spill and emergency response plan that meets the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework. Practice drills are not required.

Answer Partial Yes if: Your facility has a documented chemical spill and emergency response plan, but the plan does not meet the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework. Practice drills are not required.

Note: The ZDHC Chemical Management System (CMS) Framework can be downloaded here: https://www.roadmaptozero.com/process#Guidance    

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • How many employees were trained on this topic?
  • How frequently do you train your employees on this topic?
  • Do you evaluate your employees after the training?
    • How do you evaluate the knowledge of your employees after the training?
  • Does your facility keep records of all employee and environmental incidents related to chemical spills and emergency response?
  • Please upload documentation, if available

Suggested Uploads: 

  • Documentation that demonstrates the facility has an emergency response plan in place and that practice drills are conducted, when required (e.g., copy of emergency response plan/procedures, records of practice drills, etc.) 

What is the intent of the question?

The intent of this question is for facilities to demonstrate that emergency response procedures are in place and that employees are trained on how to respond in the event of a chemical emergency.

Technical Guidance:

The FEM aligns with the ZDHC criteria for emergency response plan content and procedures contained in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework. These criteria are summarized below:

At minimum, facilities need to have: 

  • A procedure to identify and respond to potential chemical and natural incidents related but not limited to spills, fires, accidents, injuries to employees and damage to buildings and equipment. 
  • Detailed instructions on how to evacuate the building and contain contact names/ information for individuals in charge of the evacuation. 
  • Twice per year testing of procedures which shall include all employees, sub-contractors, EMS teams, and depending on the size and scope of the drill, and the outside community EMS team. 
  • Consultation of appropriate municipal officials since control may be exercised by the local government in major emergencies and additional resources may be available. 
  • Communication and training to ensure adequate performance in times of an emergency. 
  • Methods to update procedures where necessary after practice drills and actual emergencies. All drills and follow-up should be documented.

Resources:

Chememergplan Verification And Scoring

How This Will Be Verified:

Full Points:

For facilities that use chemicals in production:

Full Points will be awarded for facilities that have a documented chemical spill and emergency response plan that meets the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework and practice drills are conducted at least twice per year for all relevant staff.

For facilities that only use chemicals for operations or tooling/equipment:

Full Points will be awarded for facilities that have a documented chemical spill and emergency response plan that meets the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework v1.0, May 2020. Practice drills are not required.

Documentation Required:

  • Documentation that shows the facility has a documented emergency response plan in place and that practice drills are conducted, when required. This may include:
    • Emergency response plan/procedures, 
    • Documentation of practice drills (e.g., drill practice/training records)

Interview Questions to Ask:

  • Staff responsible for managing the facility’s emergency response plan and procedures can explain the facility’s procedures for responding to emergencies and how drills are practiced.
  • Relevant staff understand the facility’s emergency response procedures and have participated in drill, if applicable. 

Inspection - Things to Physically Look For:

  • Observations indicate that the facility has the necessary procedures and equipment in place to respond to chemical emergencies per their developed plan. (e.g., Availability of emergency response equipment e.g., spill kits, showers, eyewash stations, fire extinguishers, SDS, emergency exits clearly marked, unobstructed and unlocked, etc.)

Partial Points:

  • For facilities that use chemicals in production:
    • Partial Points will be awarded for facilities that have a documented chemical spill and emergency response plan, but the plan does not meet the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework or practice drills are not conducted at least twice per year for all relevant staff.
  • For facilities that only use chemicals for operations or tooling/equipment:
    • Partial points will be awarded for facilities that have a documented chemical spill and emergency response plan, but the plan does not meet the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework. Practice drills are not required.

Chemsafetyequip

12. Does your facility have appropriate and operable protective and safety equipment, as recommended by the Global Harmonization System compliant (or equivalent) Safety Data Sheet, in all areas where chemicals are stored and used?  (Ref Id: chemsafetyequip)

Answer Yes if: Your facility has appropriate and operable protective and safety equipment as recommended chemical safety data sheets (SDS) in all areas where chemicals are stored and used.

Answer Partial Yes if: Your facility has appropriate and operable protective and safety equipment as recommended chemical safety data sheets (SDS) in some, but not all areas where chemicals are stored and used.

Notes: 

  • This question applies to all production and non-production related chemicals.
  • For this question the terms appropriate and operable are defined as follows:
    • Appropriate – refers to protective and safety equipment recommended for use on the SDS of each chemical or as required by a health and safety risk assessment conducted by a qualified safety professional.
    • Operable – refers to the protective and safety equipment being readily accessible to employees and maintained in good repair and/or working order (e.g., per the equipment manufacturer's specifications).

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Please upload documentation.

Suggested Uploads: 

  • Documentation that shows the facility has identified appropriate protective and safety equipment required and that the equipment is regularly replenished and/or maintained (e.g., health and safety risk assessment showing the required controls, inventory list of PPE and safety equipment with schedules of stock replenishment/replacement, equipment maintenance, etc.).

What is the intent of the question?

The intent of this question is to ensure facilities understand and provide appropriate protective and safety equipment to reduce worker exposure to health and safety risks of chemicals in the workplace. 

Technical Guidance:

Ensuring appropriate personal protective equipment (PPE) (e.g., gloves, respirators, protective clothing, etc. and other safety equipment (e.g., spill kits, eye wash stations, emergency showers, fire extinguishers, etc) is available in areas where chemicals are stored and used is crucial to protecting workers from chemical exposure risks. 

Information on the recommended safety and protective equipment may be found in the following sections of a GHS compliant SDS (note that SDS sections and content may vary by jurisdiction)

  • Section 4: First-Aid Measures
  • Section 5: Fire-Fighting Measures
  • Section 8: Exposure Controls/Personal Protection 

The selection of the most suitable PPE and safety equipment should be evaluated by an accredited health and safety professional to determine the most effective equipment and any limitations. This is particularly important for facilities that use a high number of chemicals where workers are potentially exposed to multiple chemicals and chemical mixtures.  

For all PPE and safety equipment, appropriate replacement and maintenance schedules should be defined and be based on available information such as manufacturer recommendations, onsite conditions, the level and duration of potential exposures to chemicals. 

It is also important for facilities to remember that PPE should only be used as a last resort if no other control methods are available or are sufficient. For tasks where PPE is needed, it should be selected based on a formal job hazard review that identifies the specific chemical or physical hazards and the most effective type of PPE.

Resources:

Chemsafetyequip Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have appropriate and operable protective and safety equipment as recommended chemical safety data sheets (SDS) in all areas where chemicals are stored and used.

Documentation Required: 

  • Documentation that shows the facility has identified appropriate protective and safety equipment required and that the equipment is regularly replenished and/or maintained. This may include:
    • Documented health and safety risk assessment and/or SDS showing the required protective/safety equipment.
    • Inventory list of PPE with schedules for stock replenishment/replacement 
    • Inspection and maintenance schedules for safety equipment (e.g., eyewash, emergency showers, etc)

Interview Questions to Ask:

  • Staff responsible for health and safety at the facility can explain how the facility identifies the required type of PPE and safety equipment needed.
  • Staff responsible for providing or maintaining protective and/or safety can explain the facility’s procedures for ensuring equipment is available and in good working order.

Inspection - Things to Physically Look For:

  • Observations onsite indicate that appropriate PPEs and safety equipment is available in relevant areas and are consistent with hazard classification on chemical SDS and safety equipment is accessible and functioning.

Partial Points:

  • Partial points will be awarded for facilities that have appropriate and operable protective and safety equipment as recommended chemical safety data sheets (SDS) in some, but not all areas where chemicals are stored and used. 

Chemhazardsign

13. Does your facility have chemical hazard signage and safe handling equipment in the areas of the facility where chemicals are used? (Ref ID: chemhazardsign)

Answer Yes if: Your facility has chemical hazard signage and safe handling equipment is available in all areas where chemicals are used.

Answer Partial Yes if: Your facility has chemical hazard signage and safe handling equipment in some, but not all areas where chemicals are used.

Note: This question applies to all production and non-production related chemicals.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Please upload documentation.

Suggested Uploads: 

  • Documentation that demonstrates the facility has appropriate practices and procedures to ensure that chemical hazard signage and safe handling equipment are available in areas where chemicals are used (e.g., chemical labelling/signage procedures, examples of chemical signage, inspection schedule/procedures that cover chemical hazard signage and handling equipment, etc.) 

What is the intent of the question?

The intent of this question is for facilities to demonstrate that practices and procedures are in place to ensure chemical hazard signage and safe handling equipment is in place in all areas where chemicals are stored. 

Technical Guidance:

It is important that the presence of chemical hazards in the workplace are clearly communicated and visible to employees. This helps employees understand where chemical hazards are present as well as the type of hazards that exist (e.g., flammable, toxic, corrosive, etc.).  Facilities should post signage at all areas where chemicals are stored or used. Signage should depict the hazard classification(s) of chemicals as provided on the SDS (Section 2: Hazard(s) Identification) and/or other hazard identifiers required by local law.  

Areas in the facility that may require chemical hazard signage include, but are not limited to: 

  • Receiving and delivery areas
  • Chemical storage areas (centralized warehouse and temporary storage areas)
  • Chemical process areas (e.g., manufacturing/production areas)
  • Waste chemicals storage (including chemical residues and expired chemicals)
  • Laboratories
  • Maintenance areas

Safe handling and transfer equipment (e.g., trolleys, carts, pumps) should be available at relevant locations to ensure safe handling which can reduce the potential for spills, which can result in negative impacts to workers’ health or the environment. These tools can also result in cost savings by reducing chemical loss.

Resources:

Chemhazardsign Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have chemical hazard signage and safe handling equipment is available in all areas where chemicals are used.

Documentation Required: 

  • Documentation that demonstrates the facility has appropriate practices and procedures to ensure that chemical hazard signage and safe handling equipment are available in areas where chemicals are used. This may include:
    • Chemical labelling/signage procedures with requirements for chemical hazard signage
    • Inspection schedule/procedures that cover chemical hazard signage and handling equipment. 
    • SDS that shows the hazard classes of chemicals onsite. 

Interview Questions to Ask:

  • Staff responsible for the facility’s chemical management and/or safety programs can explain the facilities procedures to ensure appropriate hazard signage is available in areas where chemicals are stored and used.
  • Relevant employees understand the facility’s chemical hazard signage and how to use the provided safe handling equipment. 

Inspection - Things to Physically Look For:

  • Observations onsite indicate that chemical hazard signage is in place in all areas where chemicals are used, and the signage is consistent with the hazards indicated on SDS.
  • Observations that indicate safe handling equipment is available and in being used.

Partial Points:

  • Partial points will be awarded for facilities that have chemical hazard signage and safe handling equipment is available in some, but not all areas where chemicals are used. 

Chempurchasereqmrsl

14. Does your facility select and purchase chemicals based on their hazards and MRSL requirements? (Ref Id: chempurchasereqmrsl)

Answer Yes if: Your facility has a documented process in place to select and purchase chemicals based on their hazards and MRSL requirements;

and all chemicals meet the requirements of MRSL and the facility’s purchasing policy;

and MRSL conformance is confirmed annually (e.g., through certificates/declarations of MRSL conformance, certificates of analysis, etc).

Answer Partial Yes if: Your facility has a documented process in place to select and purchase chemicals based on their hazards and MRSL requirements but have purchased chemical(s) that do not have sufficient documentary evidence to prove compliance to MRSL, and your facility has a clear plan for obtaining the documents from chemical suppliers within 6 months or changing to a chemical supplier who can meet the requirements in order to increase the % of compliant chemicals meeting MRSL.

Non-production chemicals and spot cleaners:

For chemicals not used in the manufacturing process (e.g., lubricants, cleaning chemicals, etc.) or spot cleaners, it might not be feasible to obtain third party certificates/declarations of MRSL compliance or certificates of analysis. For these types of chemicals, this documentation is not required, but facilities must have an established process in place to review the chemical ingredients against the MRSL to check for conformance. 

Notes:

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • If yes, do all chemicals purchased and used in production meet the facility's chemical purchasing policy?

If you select No, you will be asked the following sub question(s):

  • If no, do you have a process or plan for eliminating chemicals that do not meet the facility's chemical purchasing policy?

Suggested Uploads:

  • Documentation that demonstrates the facility selects and purchases chemicals based on their hazards and MRSL requirements such as:
  • MRSL(s) applicable to the facility (e.g., customer’s MRSL, ZDHC MRSL, combined facility MRSL).
  • Chemical purchasing policy and procedure(s).
  • Positive lists used for chemical purchasing. 
  • Third party MRSL conformance certification/test reports/declarations and/or certificate of analysis of chemical composition.
  • Chemical inventory showing MRSL compliance status of all chemicals.

What is the intent of the question?

The intent is to ensure facilities have an established process to evaluate chemical hazards and MRSL conformance during procurement and that only compliant chemicals are purchased for use at the facility.

Technical Guidance:

MRSL is a Manufacturing Restricted Substance List which can be defined as a list of chemicals that are banned from use in manufacturing. The goal of an MRSL is to ensure facilities are using the environmentally preferred chemicals that result in less harm to the environment and human health. Using an MRSL in chemicals procurement can also help ensure more consistent material compliance.

To ensure that chemicals are appropriately evaluated before purchase, facilities should:

  • Establish their own chemical MRSL that covers all MRSL requirements from clients (e.g., brands) they work with or industry initiatives they are a part of or implement a strategy to use compliant chemicals from an active list that covers all MRSL (e.g., the bluesign system).
  • Establish a process to communicate MRSL requirements to all chemical suppliers including the required evidence from suppliers  to confirm compliance (e.g., positive lists, certificates/declarations of MRSL conformance, certificates of analysis, or other relevant documentation)
  • Include MRSL compliance as a purchasing requirement for all chemicals.
    • This should include procedures to verify chemicals conform to MRSL requirements through documentation provided by chemical suppliers.
    • Where applicable, facilities should purchase chemicals that are certified to meet MRSL requirements such as bluesign approved chemistry, Ecopassport by OekoTex.
  • Ensure all chemical procurement staff are aware of MRSL requirements and the facility’s purchasing policy and procedure. 
  • For chemicals not used in the manufacturing process (e.g., lubricants, cleaning chemicals) ensure there is a process in place to, at minimum, review the list of ingredients and SDS if available against the facility’s MRSL to confirm MRSL conformance. 

It is critical that facilities discuss MRSL requirements with their chemical suppliers to determine which chemical products are MRSL compliant and the requirements for chemical suppliers to be able to demonstrate their products comply with the facility’s MRSL requirements.  

It is also important that facilities not only rely on simple declarations or assurances from suppliers alone, but ensure there is a validation processes in place to ensure compliance such as chemical composition test reports from ISO 17025 certified laboratories approved for conducting the required chemical testing or use of established positive lists that confirm compliance with applicable MRSL (e.g., ZDHC, bluesign, OEKO-TEX, etc.)
Guidance for Hardgoods facilities:

In the hardgoods sector MRSL (Manufacturing Restricted Substances List) requirements may not be available. However, there is a significant impact from the use of chemicals and therefore Restricted Lists should be used. 

For hardgoods manufacturing, black, grey and white lists are often used.  Black lists contain chemicals that are prohibited in manufacturing, grey lists contain chemicals that should be phased out from manufacturing and white lists contain chemicals that may be used.  As a summary term we have chosen “Restricted Lists”. Beyond the fact that different lists are used in the hardgoods sector, the question about selection and purchasing is also valid for hardgoods facilities.

It is expected that facilities may use either a sector-wide list, a brand-specific restricted list or create their own list. 

All textile components in the hardgoods sector (for example, products such as rucksacks, tents, etc.) should apply the MRSL criteria as outlined in the Higg FEM. 

All other components should be governed at least by a Restricted List regarding their use during manufacturing.  The restrictions on the final product, as applied through an RSL, may especially be relevant for the metal processing and electronics industry, and yet again for other sectors are not relevant.  With RSLs the management of residual chemicals on the final product is secured, however this may depend on the product and materials used. 

Three examples of “Restricted Lists” are: 

  1. The RoHS directive of the EU, the European Union.  The RoHS directive restricts residual chemicals on electronic products and is strongly linked to the EU WEEE directive mentioned in the waste section guidance.  Electronic Products that may be relevant for the hardgoods section includes Consumer equipment, Lighting equipment (including light bulbs, Electronic and electrical tools, Toys, Leisure and Sports equipment, Monitoring and Control instruments).  The chemicals that are restricted are: 
    1. Lead (Pb)
    2. Mercury (Hg)
    3. Cadmium (Cd)
    4. Hexavalent chromium (Cr6+)
    5. Polybrominated biphenyls (PBB)
    6. Polybrominated diphenyl ether (PBDE)
    7. Bis(2-ethylhexyl) phthalate (DEHP)
    8. Butyl benzyl phthalate (BBP)
    9. Dibutyl phthalate (DBP)
    10. Diisobutyl phthalate (DIBP)
      1. Maximum Permitted Concentration: 0.1%[5]
      2. Maximum for Cadmium: 0.01%[5]
  2. The GADSL (Global Automotive Declarable Substance list).
  3. The ABB List of Prohibited and Restricted Substances.

It is expected that facilities may use either a sector-wide list, a brand-specific restricted list or create their own list.

For the time being, it has been decided by the Hardgoods FEM working group, that the facilities that have not yet been exposed to the concept of MRSL or received an MRSL from one of their Brand/ Retail buyers, will not need to respond to the questions related to MRSL.

Please observe that this provision is an interim compromise in order to support hardgoods facilities that have not yet been exposed to the MRSL concept. However, we expect that these facilities as well strive for solutions related to MRSL.

Resources:

Chempurchasereqmrsl Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have a documented process in place to select and purchase chemicals based on their hazards and MRSL requirements and all chemicals meet the requirements of MRSL and the facility’s purchasing policy and MRSL conformance is confirmed annually (e.g., through certificates/declarations of MRSL conformance, certificates of analysis, etc).

Documentation Required: 

  • Documentation that demonstrates the facility selects and purchases chemicals based on their hazards and MRSL requirements. This may include:
    • MRSL(s) applicable to the facility (e.g., customer’s MRSL, ZDHC MRSL, combined facility MRSL).
    • Chemical purchasing policy and procedure(s) that include, but are not limited to:  
      • Process of communicating MRSL with the chemical suppliers,
      • Process to obtain suppliers' confirmation/declaration of MRSL compliance, 
      • Collection of up-to-date positive lists from chemical suppliers.
      • Preference/requirements for purchasing chemicals on positive lists.
    • Positive lists used for chemical purchasing. 
    • Annual third party MRSL conformance certification/test reports/declarations and/or certificate of analysis of chemical composition.
    • Chemical inventory showing MRSL compliance status of all chemicals.
  • For chemicals not used in the manufacturing process documentation that the facility has a process in place to review chemical ingredients against the facility’s MRSL. This may include:
    • SDS or TDS
    • Ingredient lists from consumer labels. 

Interview Questions to Ask:

  • Staff responsible for the facility’s chemical management program can explain how the facility established its MRSL and MRSL requirements of the facility’s chemical purchasing policy and procedure. 
  • Staff responsible for chemical procurement understand  and can explain how chemicals are evaluated and approved for purchase in relation to the facility’s MRSL and purchasing policy and procedure.. 

Inspection - Things to Physically Look For:

  • Observations onsite indicate that all chemicals in use comply with the facility’s MRSL and chemical purchasing policy and procedure (e.g., observed chemicals have been appropriately screened and there is documentary evidence to confirm MRSL conformance).

Partial Points:

  • Partial points will be awarded for facilities that have a documented process in place to select and purchase chemicals based on their hazards and MRSL requirements, but have purchased chemical(s) that do not have sufficient documentary evidence to prove compliance to MRSL and your facility has clear plan for obtaining the documents from chemical supplier within 6 months or changing to a chemical supplier who can meet the requirements in order to increase the % of compliant chemicals meeting MRSL.

 

 

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